Australia Court Rules on Application of Tax Treaty Provisions for Offshore Partnerships with U.S. Resident Partners

The Australian Full Federal Court has ruled that benefits of non-taxation as per the tax treaty between Australia and the U.S. do not apply for a Cayman limited liability partnership (LLP), although the partners are U.S. residents.
Under a previous a single judge Federal Court decision, it was held that the disposal of shares of an Australian company is not subject to taxation in Australia becau…
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